On November 15-16, 2016, representatives from Tax Executives Institute, met with officials from Canada Revenue Agency and the Canadian Department of Finance to discuss tax policy and administrative matters.

On September 29, 2016, TEI filed a submission responding to the British Columbia Commission on Tax Competitiveness’s call for feedback on how to improve BC’s competitiveness through changes to its provincial sales tax and other business taxes.

On August 9, 2016, a delegation from TEI’s Philadelphia Chapter meet with representatives from the Pennsylvania Department of Revenue to discuss taxpayer issues arising from the Department’s new corporation tax systems and procedures.

State and Local Tax - TEI’s State and Local Tax Committee - Monday, September 26, 2016

On July 6, 2016, TEI submitted comments to the Internal Revenue Service regarding its proposed regulations for 26 U.S.C. § 385, which would give the IRS broad authority to recharacterize related-party debt to equity.

On May 24, 2016, 2016, TEI submitted a letter to European Union Member States urging them to reject the Czech Republic and Austria’s request for permission to introduce a pilot program implementing a generalised reverse charge mechanism.

TEI will be commenting on Treasury’s and the IRS’s notice of proposed rulemaking, REG-108060-15, which proposes regulations under § 385 that would give the IRS wide latitude to recharacterize related-party debt as stock.

TEI is continuing to take comments on IRS Notice 2015-40, which requests feedback on how the IRS should administer to potential taxpayer changes in accounting methods in light of the forthcoming FASB/IASB requirements for recognizing revenue.

On February 10, 2016, TEI submitted a comment letter to the Financial Accounting Standards Board concerning the FASB’s proposal to require public disclosure of material terms and conditions of government assistance agreements.

On February 9, 2016, TEI submitted a letter to the Canadian Revenue Agency recommending that certain employer-provided gift cards be included in the CRA’s policy of not including small employer-provided gifts as income to employees.

Canadian - TEI's Canadian Income Tax Committee - Friday, February 19, 2016

On January 5, 2016, TEI filed an amicus brief in support of the taxpayer’s application for leave to appeal the Michigan Court of Appeals’ decision in Gillette Commercial Operations North America v. Department of Treasury and its four companion cases.

State and Local Tax - TEI's State & Local Tax Committee - Wednesday, February 03, 2016

On October 14, 2015, Tax Executives Institute filed comments with HM Revenue & Customs, the revenue authority in the United Kingdom, regarding its consultation on Improving Large Business Tax Compliance.

On October 12, 2015, TEI submitted a letter to the Canadian Department of Finance stating that a proposed expansion of the Income Tax Act’s anti-avoidance subsection 55(2) would unduly apply to routine transactions that have no anti-avoidance purpose.

Canadian - TEI's Canadian Income Tax Committee - Wednesday, October 14, 2015

On October 12, 2015, TEI submitted a letter to the Canadian Department of Finance suggesting changes for Regulation 102 to allow self-certification as to “qualifying non-resident employer” status and to eliminate the $10,000 threshold for T4 reporting.

Canadian - TEI's Canadian Income Tax Committee - Wednesday, October 14, 2015

On February 26-27, 2015, a delegation from TEI met with the Commissioner of Internal Revenue and senior officials of the IRS and with the Treasury Department’s Assistant Secretary for Tax Policy and senior officials of Treasury’s Office of Tax Policy.

On August 28, 2015, TEI submitted a letter to the Canadian Department of Finance urging exception for stock-based compensation programs from potential representation requirements at issue in proposed legislation regarding synthetic equity arrangements.

Canadian - TEI's Canadian Income Tax Committee - Tuesday, September 01, 2015

TEI's Nominating Committee will meet during the Annual Conference in Dallas in October, and in anticipation of its meeting, the committee is seeking recommendations of potential candidates for consideration.

On August 3, 2015, TEI submitted comments to the IRS on proposed regulations (REG-132634-14) relating to qualifying income from activities of publicly traded partnerships with respect to minerals or natural resources.

On July 16, 2015, TEI submitted a letter to Massachusetts Governor Charlie Baker urging his veto of the Legislature’s proposed repeal of Massachusetts’ FAS 109 deduction as part of the Commonwealth’s fiscal 2016 budget.

State and Local Tax - TEI’s State and Local Tax Committee - Thursday, July 16, 2015

On February 26-27, 2015, a delegation from TEI met with the Commissioner of Internal Revenue and senior officials of the IRS and with the Treasury Department’s Assistant Secretary for Tax Policy and senior officials of Treasury’s Office of Tax Policy.

On Nov. 18-19, 2014, representatives from TEI, led by President Mark C. Silbiger and Vice President for Canadian Affairs Paul T. Magrath, met with officials from Canada Revenue Agency and the Canadian Department of Finance to discuss tax policy.

On June 4-5, 2014, a delegation from Tax Executives Institute met with the Commissioner of Internal Revenue, the Assistant Secretary of the Treasury (Tax Policy) and other senior tax officials to discuss matters of importance to TEI members.

On September 26, TEI submitted recommendations to the Canadian Department of Finance urging revisions to draft legislation released August 29, 2014, that restrict back-to-back loans through intermediaries.

Canadian - TEI’s Canadian Income Tax Committee - Friday, September 26, 2014

On September 26, TEI filed an amicus brief with the U.S. Supreme Court in a case involving the constitutional limitations on a state’s ability to tax business income earned outside the borders of that state.

On August 1, 2014, TEI completed its first project of direct tax advocacy with China’s State Administration of Taxation (SAT), when it filed comments regarding draft administrative measures on the Chinese domestic law General Anti-Avoidance Rule (GAAR).

On May 1, TEI submitted comments to the OECD regarding its recommendations for domestic law and discussion of treaty issues that the OECD believes are necessary to address tax planning through hybrid mismatches.

TEI submitted a letter in support of legislation in Alabama (SB 74) that would establish a pre-payment, independent tribunal to hear appeals of tax assessments and other matters administered by the Alabama Department of Revenue.

State and Local Tax - TEI's State and Local Tax Committee - Friday, January 17, 2014

As you may have recently read in the tax press or heard about at TEI’s Annual Conference, LB&I has redesigned its examination process to increase the efficiency, effectiveness, and transparency of its audits.

TEI's recent comments on the OECD's White Paper on Transfer Pricing Documentation focused on the need to reduce the transfer pricing documentation and compliance burden on taxpayers by standardizing requests for such documentation across tax authorities.

On June 10, TEI submitted the following comments to the Financial Accounting Foundation (FAF) in connection with the FAF's post-implementation review of Financial Accounting Standards Board Statement No. 109, Accounting for Income Taxes (codified as

The responses of Canada Revenue Agency on excise tax matters from the December 3, 2012 liaison meeting are now available. Also available are the agendas and responses from the CRA on income tax matters.

Canadian - Developed by the Institute's Canadian Commodity Tax Committee and Canadian Income Tax Committee - Wednesday, April 10, 2013

On March 4, 2013, TEI filed a letter urging the British Columbia Ministry of Finance to formally adopt a policy of administrative tolerance for Provincial Sales Tax (PST) audits during the first year of the "new" tax.

Canadian - Prepared under the aegis of TEI's Canadian Commodity Tax Committee - Tuesday, April 02, 2013

On March 4, TEI submitted a memorandum to the MTC urging it to abandon a proposed project aimed at creating model regulations governing the use of state statutory authority to adjust income and expenses between related parties (i.e., transfer pricing).

State and Local Tax - Prepared under the aegis of TEI's State and Local Tax Committee - Friday, March 29, 2013

The Institute's letter focused on the administrative aspects of the PST Act containing comments designed to assist the Ministry of Finance with the practical, effective, and efficient administration of the new PST.

Canadian - Prepared under the aegis of TEI's Canadian Commodity Tax Committee. - Monday, January 14, 2013

The Institute's letter noted the increasing frequency with which a number of EU Member States have refused to refund VAT to businesses that are in a repayment position and urged the Commission to take necessary actions against those Member States.

The Institute's brief urged the Supreme Court of the United States to reverse lower court decisions in Alabama holding that gain from the sale of property used in a taxpayer's unitary business constituted nonbusiness income allocable in full to Alabama.

State and Local Tax - Dan De Jong, staff liaison to the State and Local Tax Committee - Monday, November 12, 2012

TEI filed comments with the Canadian Department of Finance on a government consultation relating to the use of contingent fee arrangements in prosecuting claims for the Scientific Research & Experimental Development (SR&ED) tax incentives.

Canadian - Prepared under the aegis of the Institute’s Canadian Income Tax Committee - Tuesday, October 16, 2012

The Institute's letter urges the Province to use proceeds from the tax to provide incentives for businesses that make investments in alternative fuel sources, methods for capturing emissions, or other "green" projects.

Canadian - Prepared under the aegis of TEI's Canadian Commodity Tax Committee - Monday, September 17, 2012

TEI urged the Canadian Department of Finance to revise the foreign affiliate dumping legislation released on August 14. TEI also questioned the cutbacks in the SR&ED tax incentives and the proposed withholding tax treatment of certain deemed dividends.

Canadian - Prepared Under the aegis of TEI's Canadian Income Tax Committee - Friday, September 14, 2012

Canada's House of Commons kicked off its annual pre-budget consultations with a request from the Standing Committee on Finance that participants file responses to five standardized questions. TEI's responses to these questions are now available.

Canadian - Developed by the Institute's Canadian Income Tax Committee - Wednesday, August 08, 2012

TEI's letter summarizes the Institute's general support for the HST and makes recommendations to enable the Province and taxpayers to achieve the benefits of reducing the complexity and costs of compliance with the new tax system.

Canadian - Prepared under the aegis of TEI's Canadian Commodity Tax Committee - Thursday, June 28, 2012

An anti-avoidance measure in the 2012 Canadian Budget is overbroad, TEI says, urging modifications to facilitate effective cash management and financing for foreign affiliates of non-resident parent companies.

Canadian - Prepared under the aegis of TEI's Canadian Income Tax Committee - Wednesday, June 06, 2012

TEI's letter, filed with the European Commission, expressed the Institute's general concerns regarding the EC's public consultation paper on instances of double non-taxation in the European Union's internal market.

International Tax - Prepared under the aegis of TEI's European Direct Tax Committee - Friday, June 01, 2012

The report of the Global Tax Advocacy Task Force was received by the Board of Directors on March 25, 2012. Its recommendations will be incorporated into the Institute's operations and procedures as part of TEI's Vision 20/20...

TEI's comments focus on issues relevant to non-financial institutions under the proposed regulations given the limited focus of the regulations on such issues. TEI recommends clarifying and expanding the exceptions to...

Federal - Prepared under the aegis of the Institutes's IRS Administrative Affairs and International Tax Committees - Tuesday, May 01, 2012

The Institute recommended a number of changes to clarify and simplify the temporary regulations issued in December 2011 pursuant to sections 162, 263(a), and 168, relating to materials and supplies, capitalization or deduction of expenditures ...

On February 17th, TEI submitted comments to the Organisation for Economic Co-operation and Development regarding the OECD’s discussion draft on the Interpretation and Application of Article 5 (Permanent Establishment) of the OECD Model Tax Convention, released on October 12, 2011.

International Tax - Prepared under the aegis of TEI's European Direct Tax Committee - Friday, February 17, 2012

To improve case load management by the Tax Court of Canada, TEI recommends that Canada Revenue Agency be accorded the ability to settle appeals or litigation of assessments and reassessments based on the "hazards or risks" of litigation.

Canadian - Prepared under the aegis of TEI’s Canadian Income Tax Committee. - Friday, December 16, 2011

​On December 6-7, TEI President David Penney and David Daubaras, the Institute's Vice President for Canadian Affairs, will lead a delegation of members in the 2011 liaison meetings with the Canada Revenue Agency (CRA) and the Department of Finance.

Canadian - Prepared under the aegis of TEI's Canadian Income and Commodity Tax Committees - Tuesday, December 06, 2011

Following up on an August 16, 2011, meeting with representatives of the U.S. Treasury Department and Internal Revenue Service, on September 21, 2011, TEI submitted supplemental comments regarding the Foreign Account Tax Compliance Act.

Re: SEC Staff Paper: Work Plan for the Consideration of Incorporating International Financial Reporting Standards in the Financial Reporting System for U.S. Issuers-Exploring a Possible Method of Incorporation, File No. 4-600.

On June 21, 2011, Tax Executives Institute submitted comments to Canadian Minister of Finance James M. Flaherty on a June 6, 2011, Budget proposal that will limit the deferral of partnership income earned by corporate partners.

Canadian - prepared under the aegis of the Canadian Income Tax Committee - Wednesday, June 22, 2011

On June 7, 2011, the Institute submitted comments to the IRS regarding Notice 2011-34 and the Foreign Account Tax Compliance Act, urging the government to issue additional guidance for affected persons that are not foreign financial institutions.

Federal - Under the aegis of the IRS Administrative Affairs and International Tax Committees - Wednesday, June 08, 2011

On May 31, 2011, Tax Executives Institute submitted comments to the European Commission on a Green Paper consultation titled On the future of VAT: Towards a simpler, more robust and efficient VAT system.

Voting will begin in June on a referendum to rescind British Columbia's Harmonized Sales Tax and restore the Provincial Sales Tax. TEI's letter summarizes the Institute's general support for the HST and the implications if it were to be repealed.

TEI’s comments recommend modifying current exceptions to the PTIN rules to generally exempt in-house tax professionals who prepare tax returns of entities that have an ownership or fiduciary relationship with the professional’s employer, and certain entities that the employer has recently divested.

TEI’s comments respond to IRS Notice 2010-51, relating to expanded information reporting for payments to corporations and for payments of gross proceeds and with respect to property under section 6041.

The Government of Alberta's Tax and Revenue Administration has published a new information circula on the application of the functional currency tax reporting effective for taxation years beginning after December 13, 2007 on functional currency.

The Institute also urged rejection of proposals to adopt the federal economic substance doctrine, a heavy-handed amnesty program, and that would put CPA and attorney licenses at risk for conduct marginally associated with certain transactions.

On November 17-18, 2015, representatives from Tax Executives Institute met with officials from Canada Revenue Agency and the Canadian Department of Finance to discuss tax policy and administrative matters.